U.  S.  DEPARTMENT    OF  AGRICUJLT 


COOPERATION. 

THE  POLICIES  OF  COOPERATION  BETWEEN  FED- 
ERAL AND  STATE  FOOD  AND  DRUG  OFFICIALS 
RECOMMENDED  AND  ADOPTED  BY  THE  AMER- 
ICAN ASSOCIATION  OF  DAIRY,  FOOD,  AND  DRUG 
OFFICIALS. 

State  and  Federal  Food  and  Drug  Officials: 

Your  attention  is  respectfully  called  to  the  specific 
policies  of  cooperation  between  State  and  Federal  food 
and  drug  officials  which  have  been  adopted  from  year  to 
year  by  the  American  Association  of  Dairy,  Food,  and 
Drug  Officials  upon  the  recommendation  of  its  members 
and  of  its  committee  on  cooperation.  The  last  report  of 
this  committee,  adopted  at  Portland,  Me.,  in  July,  1914, 
contained  an  outline  of  the  duties  of  the  United  States 
Department  of  Agriculture  on  the  one  hand  and  of  the 
State  dairy,  food,  and  drug  departments  on  the  other 
hand.  The  carrying  out  of  these  established  policies  of 
cooperation  requiring  continuous  work  has  been  the  first 
consideration  and  effort  of  the  Office  of  State  Cooperative 
Food  and  Drug  Control  of  the  Department  of  Agriculture. 

DIVISION  A. 

THE  FUNCTION  OF  THE  UNITED  STATES  DEPARTMENT  OF 
AGRICULTURE  IN  REGARD  TO  COOPERATION. 

The  recommendations  of  the  association  as  they  a: 
this  department  arc  as  follows: 

1.  That  the  guaranty  Legend  be  abolished. 

2.  That  an  office  be  established  in  the  Bureau  of  Chem- 
istry as  a  sort  of  clearing  house  (or  putting  into  effect  the 
policies  of  cooperation  adopted  by  the  association. 

87713—15 


3.  That  the  Secretary  of  Agriculture  invite  and  encour- 
age State  officials  to  ask  for  information  and  advice  which 
they  need  in  the  enforcement  of  their  laws. 

4.  That  the  Secretary  of  Agriculture  appoint  one  or 
more  persons  connected  with  the  Department  of  Agri- 
culture to  meet  and  act  with  the  committee  on  cooperation 
of  the  American  Association  of  Dairy,  Food,  and  Drug 
Officials. 

5.  That  there  be  created  a  joint  committee  on  defini- 
tions and  standards,  consisting  of  three  members  of  the 
United  States  Department  of  Agriculture,  three  members 
of  the  American  Association  of  Dairy,  Food,  and  Drug 
Officials,  and  three  members  of  the  Association  of  Official 
Agricultural  Chemists,  to  adopt  suitable  definitions  and 
standards  of  food  and  drug  products. 

6.  That  the  Department  of  Agriculture  supply  State 
officials  with  new  methods  of  analyses  which  have  been 
approved  by  the  Secretary  of  Agriculture. 

7.  That  the  Department  of  Agriculture  furnish  State 
officials  with  information  of  violations  of  the  Federal  law 
originating  in  their  respective  States. 

8.  That  United  States  food  and  drug  inspectors  report 
to  the  proper  State  officials  the  violations  of  State  laws 
coming  under  their  observation. 

9.  That  the  Department  of  Agriculture  and  the  food  and 
drug  officials  give  to  the  proper  State  officials  full  informa- 
tion concerning  perishable  food  or  drug  products  shipped 
from  their  States  in  interstate  commerce  with  the  request 
that  such  State  officials  make  appropriate  investigations 
of  the  source  of  such  products  and  the  sanitary  conditions 
under  which  they  are  manufactured  or  produced. 

10.  That  United  States  inspectors  at  the  request  of  State 
officials  be  instructed  to  collect  samples  of  intrastate  ship- 
ments of  food  and  drug  products  which  appear  to  be  illegal 
and  to  send  them  to  the  State  officials  concerned. 

COMMENTS  ON  THESE  RECOMMENDATIONS. 

The  Department  of  Agriculture,  as  you  are  already 
aware,  has  complied  with  the  first  five  recommendations. 

6.  The  Bureau  of  Chemistry  is  not  only  supplying  State 
officials  with  new  methods  of  analysis,  but  it  is  supplying 


them  with  the  investigational  and  scientific  data  in  the 
possession  of  the  bureau  as  fast  as  it  can  be  collated. 
Letters  received  from  many  State  officials  concerning  this 
work  indicate  that  they  consider  it  to  be  of  very  great  value 
to  them  and  that  it  is  most  highly  appreciated  by  them. 
An  effort  is  being  made  to  secure  the  assistance  of  the  State 
officials  in  making  additions  to  this  sort  of  information  from 
similar  data  in  their  possession.  If  the  work  is  carried  out 
as  it  should  be,  the  result  will  be  a  most  important  manual 
for  food  and  drug  officials. 

7.  The  bureau  is  now  furnishing  State  officials  with 
information  of  violations  of  the  law  as  soon  as  it  is  possible 
to  do  so  after  such  violations  are  passed  upon  by  the  proper 
authorities.  The  circulars  giving  notice  of  seizures,  which 
go  to  our  own  laboratories,  are  also  going  to  the  State 
officials.  These  circulars  are  prepared  as  soon  as  the  cases 
are  passed  upon  by  the  Department. 

Information  of  this  nature  may  be  given  to  State  officials 
through  the  chiefs  of  the  three  districts  of  the  bureau  while 
working  up  evidence  concerning  apparent  violations  of 
the  law  in  their  States.  This,  however,  is  a  matter  of 
detail  which  will  have  to  be  worked  out  through  the  chiefs 
of  the  three  districts. 

8.  Our  inspectors  have  been  notified  to  inform  State 
officials  of  what  appear  to  them  to  be  violations  of  State 
laws.  A  form  letter  for  use  in  making  such  reports  has 
been  prepared  for  the  use  of  our  inspectors.  Our  inspec- 
tors are  carrying  out  the  spirit  of  this  recommendation. 
Two  such  letters  received  by  me  when  I  was  in  office  in 
Texas  conveyed  to  me  valuable  information  concerning 
violations  of  the  State  law,  which  were  thereupon  stopped. 
Such  information  is  also  furnished  to  State  ollicials  by  our 
inspectors  in  person. 

9  and  10.  It  is  not  known  to  what  extent  requests  for 
such  assistance  have  been  made  to  officials  of  tin1  Bureau 
of  Chemistry  concerning  these  two  phases  of  cooperation. 
It  is  safe  to  assume,  however,  from  the  general  attitude  of 
such  officials  toward  this  cooperative  movement  that  these 
recommendations  will  be  complied  with  as  occasions  arise. 


DIVISION  B. 

THE  FUNCTION  OF  THE  STATE  FOOD  AND  DRUG  DEPART- 
MENTS  IN  REGARD  TO  COOPERATION. 

The  recommendations  of  the  American  Association  of 
Dairy,  Food,  and  Drug  Officials  with  respect  to  what  State 
officials  should  do  in  this  connection  are  as  follows: 

1.  That  State  officials  give  the  Bureau  of  Chemistry  in- 
formation concerning  violations  of  the  Food  and  Drugs  Act. 

2.  That  State  officials  give  the  Bureau  of  Chemistry  all 
new  information  which  they  secure  pertaining  to  official 
work  and  investigations. 

3.  That  State  officials  make  factory  inspections  and  other 
necessary  investigations  in  their  States  for  the  Bureau  of 
Chemistry  when  called  upon  for  such  service. 

4.  That  State  officials  place  their  inspection  forces  at 
the  service  of  the  Bureau  of  Chemistry  for  such  assistance 
as  may  be  desirable. 

5.  That  State  officials  prepare  circulars  of  confidential 
information  concerning  illegal  drug  preparations  and  send 
them  to  other  State  officials  and  to  the  Federal  officials. 

COMMENTS  ON  THESE  RECOMMENDATIONS. 

1.  This  recommendation  corresponds  to  recommenda- 
tion 8  concerning  the  duties  of  the  Department  of  Agri- 
culture. The  faithfulness  with  which  these  recommenda- 
tions are  carried  out  will  in  a  large  measure  reflect  the 
value  of  the  effort  to  establish  a  working  system  of  cooper- 
ation. Each  set  of  officials  is  continuously  learning  of 
violations  of  laws  with  which  other  sets  of  officials  are  con- 
cerned. This  is  right  where  cooperation  may  be  effective. 
Such  information  will  enable  the  city,  State,  and  Federal 
organizations  to  enforce  their  own  respective  laws  with  the 
least  expense  of  time  and  money.  Cooperation  does  not 
mean  that  one  organization  shall  enforce  laws  for  another 
organization.  This  may  be  done,  however,  with  great 
advantage  and  propriety  when  quick  action  is  imperative, 
as  when  an  illegal  product  is  shipped  interstate  and  found 
by  a  State  organization  in  original  packages  in  the  hands 
of  the  original  consignee.  The  State  organization  may 
then  perform  the  functions  of  the  Federal  organization 
and  secure  the  evidence  necessary  to  start  appropriate 


proceedings  against  the  goods  and  even  against  the  shipper 
outside  his  State,  independently  of  the  Federal  organi- 
zation. 

If  these  two  recommendations  are  earnestly  carried  out, 
the  collection  of  samples  will  be  reduced  largely  to  prod- 
ucts known  to  be  illegal  rather  than  to  products  supposed 
to  be  illegal.  This  is  where  city  and  State  officials  can 
assist  the  Federal  officials  as  well  as  each  other.  This  will 
mean  that  when  one  of  these  organizations  finds  an  illegal 
product  it  will  say  to  the  manufacturer  or  producer  of  that 
product,  "You  can  not  sell  your  product  here  or  anywhere 
else  until  it  complies  with  the  laws." 

2.  This  recommendation  that  State  officials  give  the 
Bureau  of  Chemistry  all  new  information  which  they  secure 
pertaining  to  official  work  and  investigations  corresponds 
to  recommendation  6  concerning  the  work  of  the  Depart- 
ment of  Agriculture.  Such  information  should  come  to 
this  office  and  be  distributed  among  the  city,  State,  and 
Federal  officials  and  offers  a  big  opportunity  to  such  offi- 
cials for  securing  valuable  information.  A  considerable 
amount  of  valuable  information  of  this  sort  is  now  passing 
through  this  office  to  food  and  drug  officials. 

3  and  4.  The  State  officials  whom  I  have  visited  have 
expressed  a  willingness  to  comply  with  these  two  recom- 
mendations whenever  called  upon  by  this  department. 
They  have  placed  their  inspection  forces  at  the  service 
of  this  department  for  such  assistance  as  may  be  desired. 

5.  This  recommendation  that  confidential  information 
concerning  illegal  drug  preparations  be  sent  to  other  State 
officials  and  to  the  Federal  officials  is  in  substance  the 
same  as  recommendation  1. 

Your  assistance  is  earnestly  desired  in  the  effort  to 
establish  a  continuous  compliance  with  the  recommenda- 
tions that  officials  supply  each  other  through  this  office 
with  all  new  information  which  they  secure  pertaining  to 
official  work  and  investigations. 
Respectfully, 

J.  S.  Abbott, 

Chemist  in  Charge,  State  Cooperative 
Food  and  Drug  Control. 

WASHINGTON:   GOVERNMENT   PHINTINO   OFFICE  !   1918 


UNIVERSITY  OF  FLORIDA 


3  1262  09227  1468 


